Select Committee on Culture, Media and Sport Written Evidence


Memorandum submitted by Promo Veritas

PROMOTIONAL COMPLIANCE MADE EASY

  We note that the Culture, Media and Sport Committee will be holding hearings into Call TV in November. We are pleased to supply what we hope is some relevant information for them:

Background:

  PromoVeritas are specialists in promotional verification. We seek to ensure the compliance of promoter's activities to the law and the Codes of practice and so enhance their reputations in the eyes of the consumer and the trade.

    For competitions we act as independent judges, selecting the winners on the basis of agreed criteria.

    For prize draws we randomly and without bias select the winners

    For instant wins we ensure that there are the appropriate number of prizes, that they are security marked and manually and randomly seeded into the production runs. In addition we supervise No Purchase Necessary routes that are used by promoters to avoid issued under the Lotteries Act and generally advise them on terms and conditions and fairness.

  Our mainstream clients include Coca-Cola, Budweiser, McVities, Unilever and ASDA.

  So we are the one's who have picked the winners of the Coca-Cola Win A Player promotion, the Ribena Win a Donkey promotion and the Budweiser Grand Prix World Trip Tickets.

GOOD PRACTICE IN THE INDUSTRY

  In mid 2005 we got involved with the Call TV industry and now verify all of the output of The Great Big British Quiz channel which has outputs on Sky and also late night channel 5.

  Our work for the channel included an end to end review of their internal process, from how and who prepared the rules for puzzles, created the puzzles issued the puzzles and how the answers were announced on the show.

  The aim was to reduce the risk of internal abuse, inaccuracy and unfairness in the setting of the puzzles. We have now established the following protocols

    —  Rules for any new proposed puzzle type are now approved by us in advance;

    —  All puzzles, from agreed rules, are sent to us for checking before broadcast;

    —  All approved puzzles are uniquely coded and kept securely in a password area until required;

    —  Presenters have been given guidelines on what to say and what not to say for each puzzle type;

    —  All answers are securely kept in an "answer Checker" PC in the Production Area to which only two people have access. Answers submitted by the public are entered by an operator and only if there is a match is the answer revealed.

    —  There is now an effective complaint handling process; and

    —  The No Purchase Necessary route provides an equal chance of entry.

  This last point is of special note: despite the high level of skill and judgement required to answer many of these puzzles, they would still run the risk of falling foul of Lottery regulations because of the randomness of the entry process—phone up and only a small% are ever put on air.

  For this reason, we also validate the randomness of the No Purchase Necessary route. that is available via the internet and is the chosen route for many entrants, as well as being the "get out" of problems with the Lottery act.

  Finally we also conduct random checks on the back end including the paying out of the stated prizes to the stated winners.

  Our name, PromoVeritas Ltd, is used on the website'and on screen graphics as an indication that the channel is operating fairly and above board. As a result we do receive a number of consumer complaints—directly and indirectly- but in the majority of cases, once the complainant is made aware of our presence and our processes they are happy with the situation.

  Despite being paid for by the channel, our role is still to challenge them as appropriate, and we have rejected many new types of puzzles or adjusted',the rules to ensure consistency, believability and fairness.

  As a result of the introduction of the above processes; and making them known to both staff and viewers, the channel has reduced its level of complaints, expanded its business and avoided a single incidence of internal malpractice.

  We therefore believe that even within the current legislative framework it is possible to provide the necessary integrity and independence, via the use of a third party service such as ours.

November 2006





 
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